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CCS concluded that notwithstanding the high

combined market share of the Parties in Singapore,

the Proposed Transaction is unlikely to substantially

lessen competition in any market.

There are

no significant barriers

to entry that may hinder or prevent

existing global CR manufacturers and

distributors from expanding or entering

themarket for supplyingCR toSingapore.

Existing global CR manufacturers can

easily expand production, and potential

competitors who are not currently active

in supplying CR to Singapore are able

to supply into Singapore should there

be demand for their CR. This is mainly

due to excess capacity in global CR

production. Furthermore, ease of

entry is facilitated by distributors who

can aggregate demand; and entry

for several potential competitors is

also aided by the presence of their

subsidiaries or sales offices currently

located in Singapore.

There is considerable

countervailing

buyer power

. Customers are able to (and

do) switch between various suppliers

of CR. Moreover, some Singapore

customers are part of multinational

groups which have the option of buying

CR at prices negotiated on a global basis.

Coordinated effects are unlikely to be a

concern due to

low barriers to entry

by

potential suppliers aswell as the difficulty

in monitoring prices and compliance

with any common understanding among

existing CR suppliers.

Singapore’s

demand for CR is small

in relation to the

significant excess capacity in global CR production. The

ability of the merged firm to act unilaterally (e.g. to raise

prices) is constrained as other global CR manufacturers

with spare capacity can meet such demand.

In clearing the Proposed Transaction, CCS found that:

It was concluded that the Proposed Transaction is unlikely to substantially lessen

competition in any market in Singapore, and therefore will not infringe the Act. The

Parties overlap in the supply of CRworldwide, including toSingapore. DenkaPerformance

Elastomer LLC is currently owned by Denka (70%) and Mitsui (30%). CCS issued its

clearance decision for the Proposed Transaction to the Parties on 7 May 2015.

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CCS ANNUAL REPORT 2015-2016

GUIDING YOU TO NEW HEIGHTS